IR 05000387/1979025
| ML17138B008 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/21/1979 |
| From: | Bores R, Shanbaky M, Terc N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17138B004 | List: |
| References | |
| 50-387-79-25, 50-388-79-13, NUDOCS 7912260339 | |
| Download: ML17138B008 (9) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
50"387/79-25 Docket No.
Report No.
50-388/79-13 50-387 50-388 CPPR" 101 License No.
CPPR-102 Priority A-2 Category A-2 Licensee:
Penns lvania Power and Li ht Com an (PAL)
2 North Ninth Street Allentown Penns 1 vania 18101 Facility Name:
Sus uehanna Steam Electric Station SSES) Units 1 and
Inspection At:
SSES Berwick Penns 1vania Inspection Con ted:
u ust 6-8 1979 Inspectors:
M.
N.
Shanba, Radi ati Speci al s st
. Terc, Radsatson Speciali t fzl Tg date
~ii ln date Approved by:
R. J.
Bor
, Acting Chiet Environmental and Specia Projects Section date 7 al/7 date Ins ection Summar
Ins ection on Au ust 6"8 1979 Combined Re ort Nos.
50-387/79-25 and and 50-388 79-13 A~Ad:
R 1, dd p
1
Rp (Construction and Preoperational)
programs including:
the determination of the status of implementation of the Construction Permit requirements; verifi-cation of the implementation of the Construction Permit requirements; the management controls and procedures for implementing the environmental protec-tion program during site preparation and construction; preoperational environ-mental monitoring requirements; and followup on previous inspection findings.
The inspection involved 48 inspector-hours onsite by two NRC inspectors.
Results:
Of the five areas inspected, no items of noncompliance were identi-fied 1n four areas.
One item of noncompliance (Deficiency-failure to follow procedures-detail 5.c) and one Deviation from commitments (failure to control erosion/sedimentation-detail 5.b) were identified in one area.
Region I Form 167 (August 1979)
DETAILS Persons Contacted
~R.
H. Featenby, Project Construction Manager, PP&L
~R.
G.
Mood, Senior Project Engineer-Construction, PP&L
"M. F. Basta, Supervisor Environmental Auditing, PP&L
"J.
S. Fie'.ds, Environmental Consultant, PP&L
~N.
D. Griffin, Bechtel Field Engineer, Bechtel
"T. V. Jacobsen, Project Director, Ichthyological Associates Inc.
R.
D. Kichline, Project Leader SSES, Radiation Management Corporation M. J.
Soya, Research Biologist, Ichthyological Associates J.
M. Chance, Biometrician, Ichthyological Associates
"Denotes those present at the exit interview.
Licensee Action on Previous Ins ection Findin s (Cl osed) Deviation (387/78-04-01; 388/78-03-01):
Failure to maintain and use settling basins.
The inspector determined, through discussion with the licensee and review of records, that settling basins were used at the waterfront during the construction operation.
The inspector examined the construction operations at the river and noted that the intake structure was completed and the settling basins were dismantled and the area was graded.
While the licensee's actions corrected the specific deviations identified above, a similar item was identified during this inspection.
(See Detail 5.b, 587/79-25-01; 388/79-13-01.)
(Closed)
Noncompliance (387/78-04-02; 388/78-03-02):
Failure to imple-ment/follow procedures.
The inspector determined, through site observa-tions and examination of records, that the required site inspections and documentation of these inspections were performed during 1979 as required by the SSES instructions for control of pollution associated with con-struction phase.
It should be noted, however, that a similar item was identified during this inspection (see Detail 5.c).
(Closed)
Unresolved (387/77-06-02; 388/77-03-02):
The inspector examined the neutralization procedures for the C-1 basin.
At the time of the inspection the neutralization system appeared in an acceptab',e operating condition (Detail 5.f).
Mana ement Controls a.
Assi nment of Res onsibilit The inspector reviewed, the organization and administration of the environmental monitoring programs (construction/preoperational)
with
respect to changes made since the last inspection of this area.
The preoperational monitoring programs are still being conducted by the PP8L Environmental Support Group.
The environmental protection pro-grams for construction phase are still conducted under the supervision of the PP8L Senior Project Engineer.
These programs were audited routinely by the PP8L Environmental Auditing Group.
The inspector discussed with the 1'icensee the amount of time invested by personnel in implementing the environmental protection programs during the construction phase.
The licensee stated that about 10-20K of the one Senior Project Engineer and one Project Engineer was devoted for administering these programs, however, as the preopera-tional phase approaches, an Environmental Engineer with approximately lOOX of his time devoted to these programs will be assigned to the onsite environmental protection programs.
In addition, a Committee (Pol.lution Incident Prevention Committee-PIPC) will be established to review and evaluate all environmental matters related to the flushing operation and other construction and preoperational testing procedures.
The inspector stated that this area will be reexamined during a subse-quent environmental inspection (38?/79-25-01; 388/79-13-01).
Pro ram Review and Audits The inspector discussed with the licensee program reviews and audits.
The licensee stated that both the construction pollution control and the radiological preoperational programs were audited during 1978-1979.
The inspector reviewed the audit results of an audit performed by the PP8L on September 12 and 14, 1978 concerning the implementation of the SSES program for control of pollution associated with the construction phase.
Areas reviewed during the audit included dusting control, spill control, wastes removal, sewage treatment plant operation, erosion control, NPDES implementation, followup on NRC previous inspection findings in the environmental area, and corrective actions on PP8L previous audits.
The inspector noted that the audit results were reviewed by PP&L management and that corrective actions were either completed or had been initiated on identified audit findings.
The PP8L Environmental Audit Group performed several audits of the preoperational radiological monitoring programs during 1979.
The inspector reviewed the results of these audits including the audits performed on March 13-14, May 29-30 and June 27, 1979.
Several pro-gram inadequacies were identified by the PP8L Environmental Audit Group including implementation of radioanalytical procedures and the operational condition of environmental air monitoring stations.
The inspector noted that the audit results were given to the analytical contractor, but that a reply ta the audit findings was not submitted by the contractor to PP8L within 30 days as required by the audit procedures.
The licensee stated that this area was being discussed with the analytical contractor to assure that timely replies to audit findings and that required corrective actions are taken in the futur.
Determination of the Im lementation Status of the Construction Permit
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The inspector discussed with licensee and contractor personnel the imple-mentation status of the construction permit requirements for protection of the environment.
The inspector noted that the contruction phase envi-ronmental protection program was implemented during 1978-1979 through written instruction No.
ER-100450/100508.
5.
Verification of the, Im lementation of Construction Permit Re uirements a.
Site Tour Upon arrival at the SSES site, the inspector toured the area and examined the prevailing conditions at the site and surrounding envi-ronment.
Areas examined included solid waste disposal, liquid efflu-ents, dusting control, sanitary waste treatment, wooded areas condi-tion, spill control, spoils and laydown areas, construction activi-ties near the waterfront and at the recreation area, noise levels and general environmental conditions.
b.
Erosion/Sedimentation Control The inspector reviewed the licensee records for monthly site obser-vations conducted by the licensee during 1978-1979.
The inspector noted that the erosion problems identified and documented during these site observations were corrected or that corrective action was in progress.
The inspector noted signs of early erosion at'he slopes of the Mest Lot spoils area.
The licensee stated that the area is still being
'used for disposal and that area grading and slope stabilization would be performed once the area is no longer in use.
The licensee stated that reclamation plans for this area would be developed during the spring of 1980.
During the site observations on August S, 7 and 8, 1979, the inspec-tor noted runoff water with excessive turbidity and cement material discharged from the batch plant.
The water was discharged in an uncontrolled fashion resulting in erosion/sedimentation problems at.
the C-1 access road and at the wooded area east of the C-1 basin.
The inspector stated that failure to control erosion/sedimentation was in deviation from commitments made in Section 4.1 of the Environ-mental Report and from acceptable industry practice, which provide
- for the use of settling basins to control the turbidity of all con-struction water and for the maintenance of these basins to achieve this purpose (387/79-25-02; 388/79-13"02).
Dustin Control The inspector examined the dusting condition at the site access and hauling roads.
A water sprinkler truck was being used to minimize dusting.
The inspector reviewed the weekly site observation records for 1978-1979.
The licensee's environmental protection program for the con-struction phase required by Section 3.0.3 of Construction Permits CPPR-101 and CPPR-102 requires that unsatisfactory conditions be documented and a Corrective Action Report (CAR) be prepared and sub-mitted to management.
The inspector noted that no CAR was prepared and submitted as required on an unsatisfactory dusting condition at the site identified during the weekly site observation on October 23, 1978.
The inspector stated that failure to follow program procedures was an item of noncompliance (387/79-25-03; 388/79-13-03).
Failure to comply with above procedure is a recurring item since a similar event was noted in previous NRC inspection 50-387/78-04 and 50-388/
78-04 performed on April 6-7, 1979.
Solid Maste Mana ement The inspector examined the site and noted that solid wastes, includ-ing scrap fill from cooling tower construction, had accumulated at the site.
Some of the cooling tower fill material was observed on the site hauling roads.
The licensee stated that the solid waste material will be removed from the site and disposed of at an approved landfill.
The inspector noted, through program review, that the licensee pro-gram for pollution control during the construction phase did not include specific procedures or a checklist for site examination with regard t'o solid wastes disposal.
The licensee stated that this area would be evaluated and procedures for solid wastes would be developed.
The inspector stated this item will be considered unresolved pending completion and implementation of improved controls in this area (387/
79"25-04; 388/79"13"04).
S ill Control The inspector examined the site and the surrounding environment and observed no evidence of oil spills.
The licensee's program was imple-mented for this area through the Spill Prevention Control and Counter-measure Plan.
The inspector noted an apparent acid spill at the C-1 basin area.
The amount of acid and the time of the spill were undetermined.
The inspector observed a noticeable burning of vegetation and wood mate-rial in the area where several 55 gallon drums of 66K sulfuric acid were stored near the C-1 basin.
The apparent acid spill occurred
near the discharge point of the C-1 basin.
The licensee stated that this area would be evaluated and corrective action would be taken.
The inspector stated that this item will be considered unresolved pending completion of corrective actions including improving acid storage procedures (387/79-25-05; 388/79-13-05).
Settlin Basin 0 eration g.
The inspector examined settling basin C-1 and noted that the basin had been dredged to increase the holdup time of effluents prior to release.
Dye tests were performed on a routine basis to determine the holdup times of the effluents.
The licensee records for dye tests showed that the effluent holdup time in the basin was greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at the time of inspection.
Since settling basin C-1 collects the effluents from the concrete operations, the effluents of this basin are alkaline.
This requires neutralization with acid to keep the pH within the NPDES permit limits (pH range 6 to 9)
.
The inspector examined the pH monitoring/
neutralizing system and noted that the system appeared to be in good operational condition.
At the time of inspection the effluent pH range was 6.5 to 8.5.
Sanitar Waste Treatment The inspector examined the sanitary waste treatment facility, reviewed selected logs of operating parameters, reviewed selected reports submitted relative to the NPDES Permit requirements and discussed these items with the licensee.
The inspector noted that the required monthly samples were collected by the licensee and were analyzed by a contracting laboratory, Ichthyological Associates (IA).
The inspector visited the IA laboratory near the SSES site and discussed with the laboratory and licensee representatives the water quality analytical procedures for the sanitary waste treatment plant effluent.
The inspector noted that the water quality parameters were analyzed using Standard Methods procedures.
The inspector had no further questions in this area at this time.
6.
Preo erational Environmental Monitorin Pro rams a 0 Radiolo ical Monitorin The inspector examined selected environmental air and direct radia-tion monitoring stations and reviewed environmental media radiol-ogical analytical results for 1979.
The preoperational radiological monitoring program is described in the SSES, Environmental Report-Operating License Stage (ER) and the proposed Technical Specifications in the Draft Environmental Statement (DES).
Several inadequacies and
discrepancies between the currently implemented program and that in the ER and DES were noted and discussed with the licensee.
Discre-pancies were noted in the areas of sampling locations, sampling fre-quencies, and operability of monitoring equipment.
The licensee stated that the entire area of environmental radiological monitoring would be reviewed and the preoperational monitoring program (operat-ing license stage)
once initiated, would be performed in accordance with the proposed Technical Specifications and the NRR staff position.
The inspector stated that this area will be considered unresolved and will be reviewed in a subsequent environmental inspection (387/
79-25-06j.
b.
Biolo ical/Ecolo ical Monitorin 7.
The biological/ecological monitoring programs are still being con-ducted by IA.
The inspector discussed with the licensee the perfor-mance of these programs and verified the licensee preparedness status to implement the operational phase monitoring programs.
The inspector visited the IA laboratory near the SSES site and discussed the program, gC, sampling and analytical procedures with IA personnel.
Preopera-tional biological/ecological monitoring programs were conducted in accordance with approved written procedures.
The inspector had no further questions in this area at this time.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompli-ance, or deviations.
Three unresolved items were disclosed during this inspection.
These items are discussed in Paragraphs 5.d, 5.e and 6.a.
8.
Exit Interview The inspector met with the licensee representative denoted in Detail 1 at the conclusion of the inspection on August 8, 1979.
The inspector sum-marized the purpose and scope of the inspection and discussed inspection findings, including items of noncompliance and unresolved items.
The licensee acknowledged the inspection finding t
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